SAMPAT KHIMRAJ JAIN,MUMBAI vs. JT. COMMISSIONER OF INCOME TAX RANGE 142 , MUMBAI
In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal held that the assessee had furnished sufficient documentary evidence to prove the identity and genuineness of the payments made for labour charges, and non-response from the parties to a notice u/s 133(6) was not sufficient ground for addition.
What were the facts?
The assessee, engaged in manufacturing and trading of gold ornaments, filed its return. During scrutiny, the AO made additions on account of labour charges paid to certain parties. The assessee contested this, providing documentary evidence.
What were the issues?
Whether the addition on account of labour charges is justified when the assessee has provided documentary evidence and the recipient parties did not respond to notice u/s 133(6).
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, “G” BENCH, MUMBAI
Before: SAKTIJIT DEY, HON’BLE & SHRI NARENDRA KUMAR BILLAIYA, HON’BLE
O R D E R
PER NARENDRA KUMAR BILLAIYA, AM:
This appeal by the assessee is preferred against the order dated 27/09/2024 by NFAC, Delhi [hereinafter ‘the ld. CIT(A)’] pertaining to AY 2011-12.
The sum and substance of the grievance of the assessee is that the ld. CIT(A) erred in confirming the addition of Rs.4,52,034/- on account of labor charges paid to:- i) M/s. Avani Jewellers Rs.3,27,897/- ii) Shri Jayesh Jagga Rs.1,84,347/- iii) Shri Rajesh M. Dhanak Rs.92,069/- Total Rs.4,52,034/-
Representatives of both the sides were heard at length. Case records carefully perused and relevant documentary evidence duly considered in the light of Rule 18(6) of the ITAT Rules, 1963. 2 4. Briefly stated the facts of the case are that the assessee in engaged in manufacturing and trading of gold ornaments and gold bars. It electronically filed its return of income on 30/09/2011 declaring total income of Rs. 25,91,034/-. The return was selected for scrutiny assessment and accordingly statutory notices were issued an served upon the assessee. 5. During the course of scrutiny assessment proceedings, the AO issued notices u/s 133(6) of the Act to the following persons:-
More judgments on Section 133(6)
- Adj Agri International LLP, Rajkot vs The Income Tax Officer, Ward-1(1)(1), RajkotITA 1198/RJT/2026[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Rangoli Hotel, Mehsana vs DCIT, Circle, Gandhinagar, GandhiangarITA 2286/AHD/2026[2020-21]Status: Disposed21 Oct 2026AY 2020-21
- Shree Bandharda Seva Sahkari Mandli Ltd… vs Income Tax Officer Ward -4, JunagadhITA 881/RJT/2025[2019-20]Status: Disposed19 Oct 2026AY 2019-20
- Vikas Ashokkumar Masand, Ahmedabad vs The Dy. Commissioner of Income Tax…ITA 3130/AHD/2026[A.Y. 2017-18]Status: Disposed19 Oct 2026
- Ritu Rajesh Gohil, Jamnagar, Gujarat vs ITO Ward 2(1), Jamnagar, GujaratITA 109/RJT/2026[2018-19]Status: Disposed15 Oct 2026AY 2018-19
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